A recent fine on a U.S. company while simultaneously penalizing the manager of the company's foreign subsidiary after both violated sanctions on Iran seems reflective of the increasingly aggressive nature and number of U.S. enforcement actions taken on sanctions violations during the last few months, according to several Washington trade lawyers. The fine was called “unprecedented” in early February by the Department of the Treasury. After distributing just one penalty through the first eight months of 2018, the Office of Foreign Assets Control doled out six penalties during the last four months of 2018, according to the office's records. And two months through 2019, OFAC already has administered four penalties worth more than $7 million, according to the agency, including a $5.5 million penalty against the German subsidiary of an Illinois-based company on Feb. 14.
In the March 5 edition of the Official Journal of the European Union the following trade-related notices were posted:
The Office of Foreign Assets Control added one entity and made one change to its Specially Designated Nationals List, under Counter Terrorism designations, OFAC said in a March 5 notice. The office added Harakat Al-Nujaba, a terrorism group, and updated information on Arkam ‘Abbas Al-Kabi, an Iraqi national. The terrorist group is associated with Iraq and Syria, according to the notice.
In the March 4 edition of the Official Journal of the European Union the following trade-related notices were posted:
Mexico’s Tax Administration Service is set to postpone the effective dates of recently issued regulations on simplified clearance for merchandise imported and exported by parcel and express couriers. Issued Nov. 30, the regulations set conditions and entry documentation requirements for simplified clearance, including tariff numbers and other information required for filing, as well as types of merchandise that are ineligible for the procedures. The regulations had been set to take effect March 1, with the exception of certain registration and information submission requirements that were to take effect July 1. A pre-publication version of a notice on the SAT website would delay these effective dates to Oct. 1, respectively. The notice has yet to be published in the Diario Oficial.
The Bureau of Industry and Security needs access to the State Department’s internal screening list once export controls on many firearms, artillery and ammunition are transferred from State to BIS, the Government Accountability Office said in a March 1 report. State has compiled years of information on illegitimate and bad actors in its watch list, and BIS may “lack critical information needed to effectively screen license applicants for firearms and related exports” once the transfers are finalized if it can’t get access, the report said.
Welcome to the inaugural issue of International Trade Today’s Export Compliance Daily. The International Trade Today editorial staff is pleased to deliver this complimentary launch preview to our community of trade readers for a limited time. This service was developed in response to strong market feedback indicating a dearth of reliable single-source export compliance information.
A House bill that would require the U.S. government to ban all U.S. exports to any company that violates export controls or sanctions has appeal on both the right and left, said Rep. Mike Gallagher, R-Wis., in a recent interview. The bill, H.R. 602, which so far only has Reps. Ruben Gallego, D-Ariz., and Vicky Hartzler, R-Mo., as co-sponsors, is a companion bill to a Senate effort led by Sen. Tom Cotton, R-Ariz.